Mistakes Unmistakably Increase Risk

Mistakes happen. We’ve likely all said this at one time or another, but if you are using the phrase in your food facility to justify or side-step periodic or even potential contamination issues, you should probably take another look at your programs. Although mistakes certainly can happen; in the food industry, risks unmistakably increase when mistakes happen.

Contamination “mistakes” — that is, just about any unintended adulteration of food — are the very risks which food safety programs are intended and developed to prevent. However, based on CDC’s  April 21 FoodNET report, it seems that even with the increased preventive controls that facilities are implementing, those mistakes and the resulting contamination of food are continuing to increase.

In fact, the report (Incidence and Trends of Infections with  Pathogens Transmitted Commonly Through Food and the Effect of Increasing Use of Culture-Independent Diagnostic Tests [CIDT] on Surveillance)  shows the incidences of infections as having increased for nearly all foodborne illness-causing bacteria.

That said, while there is no question that foodborne diseases represent a substantial public health concern in the U.S., CDC raises some doubt about the FoodNet data comparisons, asking the age-old question of whether foodborne illness is increasing or are we simply getting better at detecting it? In this case, the disproportionate numbers may be due in part to the increased use of Culture Independent Diagnostic Tests (CIDT) by clinical laboratories.

As CDC states, “CIDTs complicate the interpretation of surveillance data; testing for pathogens might occur more frequently because of changes in either health care provider behaviors or laboratory testing practices.” However, the report continues, “Some information about the bacteria causing infections, such as subtype and antimicrobial susceptibility, can only be obtained for CIDT positive specimens if reflex culture is performed. Increasing use of CIDTs affects the interpretation of public health surveillance data and ability to monitor progress toward prevention measures.”

But, regardless of how it is being detected and whether or not there is a significant increase, the data is clearly showing that there are still a significant number of cases of major foodborne pathogens:

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• The largest number of confirmed or CIDT positive–only infections was reported for Campylobacter (8,547), followed by  Salmonella  (8,172),  Shigella  (2,913), STEC (1,845),  Cryptosporidium  (1,816),  Yersinia  (302), Vibrio  (252),  Listeria  (127), and  Cyclospora (55).
• The proportion of infections that were CIDT positive without culture confirmation in 2016 was largest for  Campylobacter (32%) and  Yersinia  (32%), followed by STEC (24%),  Shigella  (23%),  Vibrio (13%), and  Salmonella  (8%).
• The overall increase in CIDT positive–only infections for these six pathogens in 2016 was 114% compared with 2013–2015.
• Among infections for which reflex culture was performed, the proportion of infections that were positive was highest for  Salmonella  (88%) and STEC (87%), followed by  Shigella  (64%),  Yersinia  (59%),  Campylobacter  (52%), and  Vibrio  (46%).

Similar arguments could, in fact, be made that there is an increase in pathogens being found in the food production facility because of the increased environmental monitoring required by FSMA, and that food illnesses are simply being more regularly linked to foods and production environments due to FDA’s increasing use of whole genome sequencing (WGS).

Again, however, whether there are more or we are detecting more, pathogens in the foods and the plant environment are undoubtedly the root cause of at least some of the infections — and are, now, a key factor of FDA Preventive Controls inspections. (See Pathogen: Pet or Pest, page 36, for more information on FDA inspection “swab-a-thons.”)

While it is likely that all the foodborne illnesses caused by the pathogens cited in the FoodNet report are due to unintended adulteration (rather than intentional terroristic, begrudged employee, or economically motivated adulteration), the food safety landscape is becoming more and more complex every day. At the same time, the detection of food safety issues is being heightened and the diagnosis of resulting foodborne illness increasing.

Food companies are being caught in the crosshairs of better diagnostic detection of illness in humans, linked, where possible, with whole genome sequencing; and, “pathogen mapping” of food plants by the regulators as part of “swab-a-thons.”

The bottom line is that the risks just keep going up and, without a solid food safety program and environmental controls, this complexity is likely to lead to increasing mistakes — which are not only more likely to be detected and cause for recall, but also increase the risks to consumers and your brand.